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When people think 'feedlot' this is what they picture â€” small pens of cattle with feed bunks.
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The definition of a feedlot is causing headaches for producers drought feeding cattle.

In Queensland the Government defines a feedlot as "a confined yard or enclosure â€¦ where cattle or sheep are fed entirely by hand or mechanically; and is designed, constructed or used in a way that does not allow cattle or sheep in the yard or enclosure to graze".

Matthew Norton from rural consultancy group Premise Agriculture said that meant some people drought feeding livestock could be caught accidentally lot feeding.

"The current Government definition revolves around whether those animals can graze or not," he said.

"So regardless of the stocking density â€” you could have one animal in a large paddock â€” if your supplementary feeding that animal â€¦ and putting weight on it, so you go past that drought exemption [feeding an animal to maintain its condition], that could be considered a feedlot.

"It's not about the area you are feeding them in, it's about what's on the ground and where they are getting their feed from."

Under State Government laws intensive livestock systems are highly regulated under strict legislation.

"To be a feedlot you need to put in an application, you need approvals [including environmental, from both] state and local governments," he said.

Normal grazing, by comparison, did not require any approvals.

"So if you get it wrong and all you are trying to achieve is grazing, you can then be hit with a lot of costs and getting approvals or they just tell you to shut that activity down," said Mr Norton.

However, in a written statement to the ABC, a spokesperson for the Queensland Department of Agriculture and Fisheries said "feedlotting is distinct from drought feeding of stock".

"The definition of intensive animal feedlotting and a feedlot is quite specific. The regulation provides clarity for graziers by explicitly stating activities that are exempt from obtaining an environmental authority, such as, using a feed pad in a paddock, whether or not drought feeding," the statement said.

"DAF supports the use of drought feeding in grazing production systems, but it's important that drought feeding is not intensified through the introduction of additional livestock, as this can lead to environmental management issues."

Drought feeding vs feedlotting

In southern Queensland, the State Government has issued a letter to one operation demanding the facility be shut down as it was operating as a feedlot without approvals.

Ben Cameron, a director of the Roma feedlot and spelling yards, said the feedlot was a registered facility but it was the spelling yards â€” where cattle in transit are fed, watered and rested between destinations â€” that had been called into question.

"The Government is deeming that the spelling yards are part of the feedlot â€¦ but they are two different things," he said.

"The argument we originally rebutted was that the Government says the spelling yards fit the definition of a feedlot and therefore should be classified as that.

"So they are saying we should go through another development approval process and the yards need to be shut down by the 24th of April 2019."

Mr Cameron said there were exemptions for transport, however the issue was the site also had a feedlot.

"The last correspondence I got from [the State Government] was that drought feeding exemption is not applicable where â€¦ you have a feedlot licence so therefore if you have a feedlot on your property â€¦ you can't drought feed cattle," he said.

Mr Cameron said he currently had just under 1,000 cows in the spelling facilities which he was feeding to put condition on before they were either sent home or sent to an abattoir.

The Government's position on that is that the animals should be there "for no longer than is reasonably necessary".

"I would argue that some of these animals did need the 20 to 30 days there to recover because they were in such poor condition when they arrived," Mr Cameron said.

Different feedlot definitions around Australia

The definition of a feedlot set by state governments differed from that of the industry definition which had the widely accepted view of what a feedlot is.

The Australian Lot Feeders' Association (ALFA) defines a feedlot as:

"The National Feedlot Accreditation Scheme defines a "feedlot" as a constructed facility with designated water points where cattle are confined with a stocking density (25m2 per Standard Cattle Unit or less), and are only fed a prepared ration for the purposes of production."

This is the nationally agreed feedlot definition for the production of 'certified grain fed beef', according to ALFA.

The New South Wales and Victorian Governments are reviewing their definitions.

In NSW, the draft revised definition is:

"Feedlot means a confined or restricted area that is operated on a commercial basis to rear and fatten cattle, sheep or other animals, but does not include a poultry farm, dairy, or pig farm, or extensive agriculture."

Calls for one definition of a feedlot

Mr Norton said there needed to be one nationally agreed definition of a feedlot.

"Industry needs to get together within themselves and put one simple, clear message out and take that to government as the only way forward," he said.

However changing legislation could take years, so he said in the meantime producers should maintain some grass cover to avoid being caught in this situation.